New Hampshire's Site Evaluation Committee is deliberating on Noble Environmental's  proposal to erect a 99-megawatt wind energy facility in northern Coos County.

The project has caught the attention of several high profile environmental groups in the State including New Hampshire Audubon, The Nature Conservancy, and Appalachian Mountain Club (AMC) - all of whom issued strong letters, and in the case of AMC, testimony, detailing the significant impacts to sensitive wildlife habitat should the project proceed.  Biologists at New Hampshire Fish and Game (NHF&G) submitted equally strong testimony arguing the project will produce an unreasonable adverse effect on the natural environment.

The facts proffered by the above mentioned groups are consistent.

The project located on managed timber land spans four ridgelines. The bulk of the thirty-three turbines are slated for rare, pristine old-growth forest that, according to NH's Wildlife Action plan accounts for only about four-percent of the state's land area but whose habitat type supports sixty-six vertebrate species including several threatened species. In particular, this high-elevation spruce-fir forest is home to the Bicknell's thrush, American martin, and the three-toed woodpecker, all known to be resident at the project site. Tracks of the Canada lynx, now believed to be pioneering back to the State have been observed onsite.

The project proposes to build 33 miles of roads involving 50-foot ledge cuts and surface widths ranging from 24 to 150 feet wide. Noble's engineer confirmed under oath that this photo taken at the Kibby Mountain wind facility in Maine accurately represents what can be expected in New Hampshire.

The project also seeks to fill over thirteen (13) acres of wetlands including the destruction of eight vernal pools.

The US Army Corps of Engineers has informed Noble that the alternatives analysis conducted on the project is inadequate and more needs to be done to prove that the proposed site location and plan layout is the least impacting. Technical letters prepared by the US Fish and Wildlife Service and EPA concur with the Army Corps finding.

Still, Noble Environmental has resisted all requests to relocate or remove turbines that might reduce the environmental damage complaining that any changes to the plan will harm the project's economic viability. No concrete evidence has been supplied by Noble to substantiate this point.

But it would appear that by Noble holding firm at least two parties have caved to its will - AMC and NHF&G. In the final days leading up to the State hearings, AMC, NHF&G, and Noble hastily slapped together an agreement termed the High Elevation Mitigation Agreement. The key conditions of the agreement are simple:

1) Land surrounding one of the four turbine strings sited on one of the four peaks (Kelsey Mountain) will be deeded to the State of New Hampshire as conservation land.

2) Two offsite parcels totaling 260 acres will be deeded to the State.

3) Funds totaling $950,000 will be paid to NHF&G of which $200,000 will be used to conduct post-construction studies on the effects of wind facilities on high-elevation species and the remaining $750,000 will go towards purchasing additional conservation lands.

AMC's and NHF&G's firm opposition to certain turbine strings being constructed was not firm at all. When faced with a choice between managed commercial timbering in the area - a regulated industry active in the state for decades (and now green-certified) - and the project, the project was deemed the lesser evil.

This position taken by AMC and NHF&G is even more incredible after considering AMC's David Publicover's own statements that timbering at high elevations in New England typically produces low commercial value and the steep slopes significantly impede harvest due to cost. This aerial photo of the Kelsey ridgeline showing an area near-black with forest appears to validate this point.

The haste in which the agreement was negotiated and signed did not go unnoticed during the hearings. Windaction.org, a party to the proceedings before the State, had the opportunity to cross-examined AMC and NHF&G on the agreement, a summary of what was revealed detailed below:

Did AMC or NHF&G perform a trade-off analysis that looked at total acreage impacted by the project including forest interior habitat lost?

Answer - "No." NHF&G stated in testimony that 3747 acres of high-elevation habitat would be affected.

Did AMC or NHF&G consider how far into the forest the direct edge effects of building the road, turbine pads, and associated transmission would be felt?

Answer - "No." AMC's Dave Publicover added under oath that "We knew those edge effects were there. We knew approximately what they were. ...We weren't basing our mitigation on any specific, you know, mitigation acreage ratio."

Did AMC or NHF&G visit the mitigation land to determine the quality of the habitat and whether it was comparable to the habitat that would be lost?

Answer - "No." In fact, some of the mitigation land was recently timbered, confirmed in aerial photos obtained by Windaction.org.

Did AMC or NHF&G prepare a scope of work for any post-construction studies and did either validate whether the $200,000 was sufficient to cover costs including administrative costs?

Answer - "No."

Did either AMC or NHF&G consider how much land could be purchased for the $750,000 and the availability of comparable habitat elsewhere in the State that was not already protected?

Answer - "No." Under oath, NHF&G stated it was difficult to tell what landowners will demand for land but the Department knows of several properties that had recently been cut.

It remains to be seen whether the State of New Hampshire will endorse the agreement signed by NHF&G, AMC, and Noble Environmental. Windaction.org would hope the Committee will hold a higher standard for the State than what NHF&G and AMC have demonstrated. The lesson learned in this case is that we cannot assume those negotiating mitigation settlement agreements have the knowledge, experience, or commitment to protect the natural resources at stake, even when that's their job. 

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In September, the U.S. Forest Service released its Draft Environmental Impact Statement (DEIS) for the first wind energy project proposed for national forest lands.

Iberdrola's Deerfield Wind application proposes to erect fifteen 2-MW turbines in the Green Mountain National Forest located in southern Vermont. The project site is adjacent to the older Searsburg project erected on private land in 1997.

A review of the DEIS reveals disturbing information regarding the Forest Service's assessment of this project's impacts in the context of the National Environmental Policy Act or NEPA.

The "purpose and need" section appears designed to achieve a predetermined result of siting an industrial wind energy facility on Forest Service land adjacent to the existing Searsburg site. Justifications used for considering the project application include (quoting the document):

• "The Project would provide a reliable and much needed source of power, contributing to long-term cost stability, in a region where the availability of cost-stable resources is quickly diminishing", and
  

• "The addition of wind energy to the regional electric grid has the benefit of decreasing the emission of harmful air pollutants, and decreasing reliance on natural gas and other fossil fuels."

Neither statement is accurate nor is there any attempt to substantiate these assertions. The Forest Service has no basis for claiming the project will provide "long-term cost stability" given the unpredictability of the wind resource and Iberdrola's inability to secure a long-term power purchase agreement for the energy. Since the New England states are participants in the regional cap and trade program, Regional Greenhouse Gas Initiative or RGGI, the Forest Service cannot claim emissions will decrease should the project be built. Emissions will only be displaced.

In the alternatives analysis, the Forest Service never contemplates an alternative where the project is built on private land, an obvious omission. The only three alternatives provided, including a 'No Build' option, reflect variants of the original. The message is clear -- the Forest Service is committed to seeing this project built here and built now.

But the most offensive aspect of the DEIS document is how it reads more like a repackaging of Iberdrola's application rather than a serious assessment under NEPA in many important topics including aesthetics, economic benefits, impact on wildlife and the natural environment, and safety (ice throw, blade and turbine failure). It appears the Forest Service shamelessly accepted Deerfield Wind's studies, with no apparent attempt to validate the assumptions and conclusions made by the developer on project benefits and impacts.

For example, on Noise impacts, the Forest Service accepts Iberdrola's recommendation that the Project meet a nighttime guideline for protection against sleep disturbance of 45 A-weighted sound pressure levels (dBA) averaged over an eight-hour night at the wall of nearby residences.

By doing so, the Forest Service ignores the growing body of data, detailing the risk of turbine noise in rural communities. WHO recommends that sound levels during nighttime and late evening hours be less than 30 dBA during sleeping periods and that for sounds containing a strong low frequency component (typical of wind turbines), WHO asserts these limits may need to be even lower to avoid health risks. They also recommend that the criteria use dBC frequency weighting instead of dBA for sources with low frequency content.

The Forest Service also fails to note that the International Standards Organization (ISO) in ISO 1996-1971 recommends 25 dBA as the maximum night-time limit for rural communities. Sound levels of 40 dBA and above are only appropriate in suburban communities during the day and urban communities during day and night. There are no communities under this standard where 45 dBA is considered acceptable at night.

It's not possible to determine whether the Forest Service willingly conceded its responsibility to Iberdrola in assessing the impacts of the project or whether it did so out of ignorance, but the outcome is the same.

If the Federal Government is serious about understanding and documenting the impacts of wind energy projects on our National Forests, the American public deserves more. This DEIS cannot be allowed to set a precedent. Windaction.org advises the Forest Service to scrap the Deerfield Wind DEIS and begin again, but this time with a focus on research, not reproduction.

If our readers share these concerns, please take a moment to e-mail your thoughts to the Forest Service. The deadline for comments is Friday, November 28.

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The New York Times recently published "Thinking Anew About a Migratory Barrier: Roads" in which reporter Jim Robbins explores the impacts of road development on wildlife habitat at Glacier National Park in Montana.

Noting that scientists now understand the impacts of roads crisscrossing the landscape, Robbins writes "Some experts believe that habitat fragmentation, the slicing and dicing of large landscapes into small pieces with roads, homes and other development, is the biggest of all environmental problems."

Dr. Michael Soulé, retired biologist and founder of the Society for Conservation Biology is quoted: "It's bigger than climate change. While the serious effects from climate change are 30 years away, there's nothing left to save then if we don't deal with fragmentation. And the spearhead of fragmentation are roads."

For perspective as to the enormous roads which have been built along forested Appalachian ridgetops for industrial wind energy projects, Windaction.org examined these images prepared by Dan Boone, which provide before and after aerial photos of the very southern end of the NedPower windplant in West Virginia. The NedPower facility is the most recently constructed wind energy project in the mid-Atlantic region, comprised of 132 2-MW Gamesa wind turbines, each nearly 400 foot tall and a 3-blade rotor assembly with diameter of more than 260 feet.

The average width of the area bulldozed for the road corridor and other project infrastructure varies from about 75 to 100 feet. We estimate that over a square mile of forest was lost due to this one wind facility, about 650 acres, or roughly 5 acres of forest cleared on average for each wind turbine. The forest acreage loss is greatly exceeded by the amount of ecologically-significant "forest-interior" habitat that was eliminated by the extensive fragmentation of the area's forest coverage.

From an ecological perspective, roads create "edges" which severely affect "forest interior" wildlife.  For example, woodland birds which nest near forest "edges" are more likely 1) to have their eggs or young taken by scavengers/predators who disproportionately frequent "edges", and 2) to be "parasitized" by brown-headed cowbirds who lay their eggs in other birds' nests. In addition, there are a host of ecological concerns associated with created "edges" within the "forest interior" such as:

1) increased sunlight and evapotranspiration (drying) which changes vegetation structure and composition along the zone of forest that adjoins edges, with penetrating effects up to several hundreds of feet, and

2) greatly increased dispersal and colonization of forest edges by invasive, non-native species of plants and animals.

Wind developers typically downplay the size of the roads and press for mitigation to compensate for the impacts. But it's nonsensical to assume 'X' acres of disturbed forest-interior can be mitigated with 'Y' acres of some arbitrary parcel some distance away.

Trisha White, director of the Habitat and Highways Campaign for Defenders of Wildlife notes, "the downside of mitigating road impact is thinking that it heals all wounds. The biggest danger is thinking that we can put in new roads with crossings and things will be just fine. There are so many more impacts. Nothing could be more incorrect.”

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National Audubon’s newly released position statement on wind energy development is short, sweet, and dangerous.  Notable deficiencies in the Statement include:

1) Audubon’s use of italics of the word "population" in an apparent effort by Audubon to a) limit concern over wind plant development's impact to wildlife species and b) discourage concern over the numbers killed.  The notion that only "population" level impacts should be of concern is an unacceptable flaw in this document since no one can determine what constitutes a "population" for most species of nocturnal migrant songbirds or bats. 

2) Audubon asserts that “habitat impacts” can occur and fails to acknowledge the considerable habitat loss that IS OCCURRING.  The document omits the term “fragmentation" when describing impacts of wind energy development and appears to only grudgingly concede there may be impacts.

3) Audubon's call for guidelines is weak, and represents thinking that is several years behind the times.  Guidelines that do not require mandatory compliance by the wind industry are meaningless. We question whether Audubon understands that the U.S. Fish and Wildlife Service has had wind/wildlife guidelines available for 5 years and that this voluntary guidance has been largely ignored by the wind industry.

4) Most egregious is Audubon’s failure to recognize the threat of wind energy development on our national forests and state-owned lands. Audubon should be calling for a ban on wind development on public lands as long as suitable privately-owned lands are available. Further, Audubon should be insisting that wind projects on public lands comply with more stringent siting and monitoring requirements than any provided via "guidelines".
(Analysis by D. Daniel Boone)

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